1. Definitions

Qualifying Disclosure: A disclosure of information made in good faith, where there is reasonable suspicion that Homecubes Management FZE (“Homecubes”), or any of its employees or officers, has or may have:

Contravened a provision of any applicable law administered by the Dubai World Trade Centre (DWTC), the governing authority regulating Homecubes;
Engaged in money laundering, fraud, corruption, bribery, or any other financial crime.
Staff, “You”, “you”, “Your”, “your”: All Homecubes directors, officers, agents, employees, temporary workers, interns, consultants, contractors, vendors, or any other person employed by or working for Homecubes, regardless of the duration of their employment or contractual relationship.
Homecubes, “We”, “we”, “Our”, “our”: Homecubes Management FZE and all affiliated entities, including subsidiaries and joint ventures under its control.

2. Purpose

We are committed to establishing a robust whistleblower framework that protects individuals who make disclosures. The primary objective of this policy is to ensure that no whistleblower shall, as a result of making a disclosure:

Be subject to civil or contractual liability;
Have any contractual, civil, or other remedies or rights enforced against them;
Be dismissed from employment or subjected to retaliation or any action that may cause them harm.

3. Scope

This policy applies to all Homecubes staff and relevant third parties, including contractors and vendors.

4. Compliance Officer’s Role and Responsibilities

The Compliance Officer is responsible for:

Overseeing the management, implementation, and compliance with this policy;
Referring concerns to appropriate departments for investigation and resolution;
Communicating with relevant employees and third parties regarding disclosures made under this policy;
Ensuring the confidentiality and integrity of the whistleblowing reporting mechanism;
Monitoring the effectiveness of investigations and maintaining oversight of related processes.

5. Qualifying Disclosure

A Qualifying Disclosure is a report made in good faith regarding reasonable suspicions of misconduct, including:

Contravention of any applicable laws administered by DWTC;

Financial crimes such as money laundering, fraud, or embezzlement.

5.1 Examples of Misconduct

Fraud: Includes theft, corruption, bribery, forgery, misrepresentation, collusion, money laundering, or any intentional act of deception for personal or third-party gain.
Money Laundering: The process of disguising illicit funds to make them appear legitimate.

6. Protection of Whistleblowers

Homecubes is committed to protecting whistleblowers and ensuring confidentiality. Disclosures will be handled in accordance with ethical and legal standards, and whistleblowers will be protected from:

Disclosure of their identity or personal details;
Retaliation, harassment, or unfair treatment;
Any legal action arising solely from their disclosure unless the report is proven to be false or malicious.

7. Reporting Concerns

Concerns regarding actual or suspected wrongdoing may be raised via the following confidential reporting channels. All reports will then be sent directly to our Compliance Officer by email: compliance@homecubes.com

Employees may raise concerns of suspected wrongdoing in writing, with their line manager. If an employee does not feel comfortable to raise the concern with his/her manager, this can be raised with an alternative manager. The matter should then be immediately referred to the Compliance Officer by the manager who has received the report.

7.1 Recordkeeping of Concerns

All whistleblowing reports will be logged, and investigations will be conducted where credible evidence is provided. Reports should include as much detail as possible (e.g., names, dates, supporting documents) to facilitate investigations. Anonymous reports may be submitted but may limit the ability to conduct a thorough investigation.

Knowingly submitting a false report for personal gain or malicious intent may result in disciplinary action, including termination.

8. Investigation Process

Upon receipt of any concerns raised under this policy, our Compliance Officer will evaluate whether the concern is within the scope of this policy and will assess the severity of the concern and determine whether a further investigation is required to properly resolve the matter.

Appointed investigators will be completely detached from any teams related to the subject matter of the reports. Investigations may, in certain circumstances and particularly where the matter is sensitive or serious, be conducted by external parties and/or relevant regulators and authorities.

We are committed to the fair treatment of all individuals who are involved in an investigation, including those who are under investigation or those whose identity becomes relevant in the course of an investigation.

8.1 Filing to Authorities

If the result of the investigation and legal advice results in evidence of criminal activity, applicable laws and procedures shall be followed including filing to the relevant authorities in the UAE.

8.2 Violations

If an employee violates this policy, action will be taken according to the relevant laws in the UAE.

9. Policy Maintenance

This policy will be reviewed each calendar year by the Compliance Officer.